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Mh <br /> <N California a conal Water Quality Cloontrol Board <br /> Central Valley Region <br /> Alan C.Lloyd,Ph.D. Robert Schneider,Chair Arnold <br /> Secretaryfor Sacramento Main Office hwarzenegger <br /> Environmental 11020 Sun Center Drive#200,Rancho Cordova,California 95670-6114 vernor <br /> Protection Phone(916)464-3291•FAX(916)4644645 <br /> http://www.waterboards.ca.gov/centralvalley <br /> 0 <br /> 28 July 2005 <br /> Benjamin Hall Nick Musco <br /> Musco Olive Products, Inc. Studley Company <br /> 17950 Via Nicolo 17950 Via Nicolo <br /> Tracy, California 95376 Tracy, CA 95376 <br /> PLANS AND FINANCIAL ASSURANCES FOR CLASS H SURFACE IMPOUNDMENTS, <br /> MUSCO OLIVE FAMILY COMPANYAND THE STUDLEY COMPANY,SAN JOA QVIN <br /> COUNTY, FACILITYNO. 5B392059001 <br /> We have reviewed your letter of 15 June 2005, which provides your response to the Regional Board's <br /> letter of 15 May 2005 (see attached). Based on our review, we find Musco has not specifically followed <br /> the requirements; therefore, we find the document incomplete. <br /> Your letter generally described that Musco,not a third party, would perform a clean closure of the <br /> surface impoundments. Your cost estimates accounted for cleaning the ponds and reusing them as <br /> stormwater ponds once you verify no contamination remains at each pond. Correction of a foreseeable <br /> release sets up a scenario of performing a leak detection survey, removing some or all of the wastewater <br /> for repairs and then the return of wastewater to the pond. The proposed Letter of Credit is to be <br /> incrementally funded over the next four years. <br /> The intent of the four itemized sections in the WDRs under Financial Assurances, as discussed in our 15 <br /> May 2005 letter, require a separate plan for closure and postclosure maintenance with an associated <br /> financial assurance mechanism payable to the Regional Water Board to access in case a third party is <br /> needed to close the site. Therefore, we require a detailed closure and postclosure maintenance plan for <br /> performing this function. Of course, if clean closure were the closure option,then a postclosure <br /> maintenance plan would not be necessary. A plan must include the design, construction,materials, <br /> transportation, construction quality assurance, contingency costs, time schedule with associated itemized <br /> cost estimates (table format) for closure of the surface impoundments by a third party contracted by the <br /> Regional Water Board. <br /> A separate plan and financial assurance mechanism for any foreseeable releases follows the same <br /> scenario. <br /> The two plans must include not only third party costs, but the assurance that closure and/or cleanup of <br /> each surface impoundment be under the direct supervision of a California registered civil engineer or <br /> certified engineering geologist. Therefore,the cost estimate table(s) should include the costs of a <br /> professional who will certify closure of the site and/or sign off on a cleanup plan for any foreseeable <br /> releases. <br /> California Environmental Protection Agency <br /> ��Recycled Paper <br />